IR 05000267/1985030

Insp Rept 50-267/85-30 on 851005-1130.No Violation or Deviation Noted.Major Areas Inspected:Operational Safety Verification,Previous Insp Findings,Winter Protection, Surveillances & Part 21 Review

ML20137G977
Person / Time
Site:	Fort Saint Vrain
Issue date:	01/09/1986
From:	Farrell R, Ireland R, Jaudon J, Stewart R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20137G966	List: IR 05000267/1985030 ML20137G962
References
50-267-85-30, NUDOCS 8601210361
Download: ML20137G977 (8)

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APPENDIX

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U. S. NUCLEAR REGULATORY COMMISSION

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REGION IV

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NRC~ Inspection Report: 50-267/85-30 License: DPR-34

. Docket: 50-267-Licensee: Public Service Company of Colorado (PSC)

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. P - 3. Box 840 Denver, Colorado 80201 Facility Name: Fort St. Vrain Nuclear Generating Station Inspection At:

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Fort St. Vrain Nuclear (FSV) Generating Station, Platteville,

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Colorado Inspection Conducted: October 5 - November 30, 1985

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, Inspector: r .

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R'. E. Fa'rrell, Senior Resident Inspector (SRI) Date m /

Inspector: A ge / 8 [l>

R. C. Stewart, Reactor Inspector Date'

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_ Approved: . /M do'il, Chi 6f,~ Project Section A

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[.]P.J RGac r Projects Branch DA }l7/WA

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, t, . Ireland, chief, Operatiohs Section, 'Date Reactor Safety Branch

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B601210361 860113 PDR ADOCK 05000267 G PDR-4

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Inspection Summar Inspection Conducted Octob'er 5 through November 30, 1985 (Report 50-267/85-30)

t' , Areas Inspected: - Routine, unannounced inspection of operational' safety

- ' . verification, previous inspection findings, winter protection .surveillances, and 10 CFR 21 review. The inspection' involved 164 inspector-hours onsite b ,wo NRC inspector '

'Results: iWithin the five areas inspected,.no violations or deviations were identified.~

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DETAILS Persons Contacted Principal Licen'see Employees D. Alps, Security Supervisor T. Borst, Support Services Manager / Radiation Protection Manager

• R. Craun, Site Engineering Manager

• Deniston, Shift Supervisor

• J. Eggebroten, Superintendent Technical Services Engineering

• D. Evans, Superintendent Operations M. Ferris, QA Operations Manage *C. Fuller, Station Manager

• S. Hofstetter, Nuclear Licensing Engineer

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• J. Gahm, Manager Nuclear Production'

• F. Novachek, Technical / Administrative Services Manager

• T. Prenger, QA Services Manager

• L. Singleton, Manager QA

• D. Warembourg, Manager Nuclear Engineering The SRI also contacted other licensee and contractor personnel during the inspectio * Denotes those attending the exit interview conducted December 2, 198 ' Operational Safety Verification The SRI reviewed licensee activities to ascertain that the facility is being operated safely. and in conformance with regulatory requirements and that the licensee's management control system is effectively discharging its responsibilities for continued safe operatio The review was conducted'by direct observation of activities, tours of the facility, interviews and discussions with licensee personnel, independent verifications of safety system status and limiting conditions for ,

operations, and review of facility record Logs and records reviewed-included:

. Shift supervisor logs

. Reactor operator logs

. Equipment operator logs

. Auxiliary operator logs

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. Technical specification compliance logs

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.< 0perations deviations reports

. Temporary configuation reports During tours of accessible areas, particular attention was directed to the

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I MoniAoringinstrumentation

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.~ Radiation controls

. ~ Housekeeping

.. Fluid leaks

. Piping vibrations

. Hanger / seismic restraints

. Clearance tags

. Fire hazards Control room manning

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Annunciators

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No violations or deviations were identifie . Previous Inspection Findings (CLOSED) Open Item (50-267/8519-01): Control Rod Drive Mechanism Surveillance Procedures. .The licensee incorporated ~the interim Technical Specification surveillance requirements for control rod drive mechanisms in approved surveillance procedures. This was verified prior to the' plant going critical in July 1985, but was not previously documented in an inspection repor ,

-This item is close (CLOSED)Open-Item (50-267/8519-02): Verification that Surveillances are

Current. This item required verification that the plant surveillances required by Technical Specifications were current prior to the plant going

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critical. This was done prior to the plant going critical in July 1985, but was not previously documented in an inspection repor This item is close h

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- Winter Protection The SRI reviewed the Technical Specifications for winter protection

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requirements. The Technical Specifications do not~ address winter protection. The licensee did commit in response _to IE Bulletin 79-24-that all piping exposed or subject to possible freezing is. insulated, heat traced, or otherwise protecte The licensee has a list of all involved heat tracing and has verified that all involved heat tracing is operable. The SRI reviewed the licensee'_s list of heat trace circuits and interviewed plant management regarding heat trace statu . No violatio'ns or deviations were identifie . Surveillances lhe SRI reviewed' selected surveillance procedures for compliance with Technical Specifications and observed performance of selected portions of these procedures. Procedures reviewed this inspection period included:

. SR 5.4.1.3.2.b-M, "Feedwater Flow Test"

. ESR 8.1.la-1.5Y, " Radioactive Gaseous Effluent System Calibration"

. RP-7, " Calibration and Maintenance of Bourdon Tube Pressure Gauges" During performance of step 5.12.9 of Procedure ESR 8.1.la-1.5Y, control m room annunciator light Cl-1 in aisle 1 should have lit according to the procedure. Instead annunciator light A3-6 in aisle 3 lit. The control

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room operator informed the .TKI and the licensee's I&C technician that a plant modification had ' oeen performed that transferred the annunciator function of winaow'Cl-1 in aisle 1 to window A3-6 in aisle Subsequent interviews with plant personnel confirmed that plant design

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changes are reviewed for effect on plant procedures and that procedures are to be revised as required. The change to Procedure ESR 8.1.la-1.5Y was not identified in this review. There was no safety significance and no other examples of items missed in this review were identified. This is

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considered an isolated inciden No violations or deviations were identified.- Followup Review - Reported Part 21 During the period October 22-25, 1985, a Region IV inspector conducted a followup review of a 10 CFR21.21 report, including 14 exhibits, dated November 5, 1984, which has been submitted by the law firm of Bernstein &

Longest in behalf of a consultant formerly employed by PS n -

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-6-Background The consultant's concerns were relative to disagreements which he had with the PSC Nuclear Engineering Department (NED) concerning dispositions of findings identified during a piping and support seismic qualification audit (Audit QAA-1401-82-01) performed by him as an audit team leader during the period December 1982 through January 1983. This audit was conducted in conjunction with the licensee's major piping hanger rework and seismic redocumentation program resulting from IE Bulletin 79-14

" Seismic Analyses for As-Built Safety-Related Piping Systems," dated i

July 2, 1979, and supplement dated August 15, 1979.

i On November 5,1984, prior to the submitting of the 10 CFR 21.21 report by Bernstein & Longest, the consultant had expressed his concerns (telephon-ically) with members of the NRC Region IV staff; in this telephone call, one consultaat condensed a number of his numerous concerns into three principle questions:

. What was the status of two corrective action action requests (CAAR 599 and CAAR 600) initiated as a result of audit findings?

. Was there a 10 CFR 21 evaluation performed by the appropriate committee; how was it handled; and what was the disposition?

. Was the NRC aware of audit results in conjunction with Bulletin 79-14 and were they satisfied?

The consultant also amphasized that his concerns were not a safety problem as such, but rather he believed that they were a question of procedures (on use by the licensee) and/or a lack of licensee procedures. The consultant also questioned the licensee's methodology for closing audit item Documents Reviewed

. 10 CFR 21.21 Report (including 14 attached exhibits) dated November 5,1984 (Exhibit 11 is a copy of the final audit report datedMarch9,1983).

. PSC Part 21 Report evaluation P21-0019, initiated by the QA manager in behalf of the consultants, dated September 27, 198 . File folders retained by the licensee's Nuclear Engineering Department (NED),includingauditnotes, comments,andcalculation . QA/QC document control files, including CAAR 599 and CAAR 600 disposition evaluations, dated October 10, 198 . NRC IE Inspection Reports: 50-267/79-14; 79-19; and 83-15, dated October 16, 1979, December 26, 1979, and June 24, 1983, respectivel _ _ _ _ - - _ _ _ _ _

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.~ PSC seismic piping redocumentation status reports to NRC: PSC letters P-77198, dated September 22, 1977; P-79161, dated -

August 1, 1979; P-79198, dated September 4, 1979; P-79238, dated-October 15,1979; P-30029, dated February 15, 1980; P-80091, dated April 23, 1980; P-80194, dated June 30, 1980; P-80282, dated August 25, 1980; P-80380, dated October 28, 1980; P-80442, dated Decembe: 23, 1980; P-81019, dated January 20, 1981; P-81172, dated June 18, 1981; P-82004, dated January 4, 1982; P-82174, dated June 1, 1982; P-83113, dated March 21,* 1983; and P-84054, dated

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. PSC procedures: SDCC 005, 007, 010, 011, 012, 014, 019, 021, 024, and 025; QACP.3-10, and QACP 3-1 .

. PSC FSAR, Sections 1.4.5-1, 14.1.1.1, and Appendices B, C, and Findings 1 The final disposition and closecut of CAARs 599 and 600 were completed on October' 10, 1984. This was subsequent to the licensee's internal

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evaluation review and disposition of the Part 21 report evaluation (submittedJanuary 26, 1984, and closed September 27,1984). The consultant's contract with PSC was not renewed subsequent to December 1983; therefore, he was not cognizant of the final disposition of his reported concerns and audit finding During the documentation review, the NRC inspector reviewed the PSC internal Part 21 report evaluation. It was noted that the PSC QA manager

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submitted the consultants itemized concerns (letter NPC 3748), CAARs 599 and 600 to the PSC Part 21 evaluation team on behalf of the consultant on January 3,1984.

In reviewing the referenced documents related to the resolution and disposition of the above matters, the NRC inspectors found no problems with the licensee's disposition and close-out, in that the concerns were not reportable within the meaning of "a substantial safety hazard" as stipulated in 10 CFR 21.2 '

In addition, the NRC inspector reviewed NED file folders which included a copy of the original draft audit report containing handwritten comments and notes (undated), stated to be made by the consultant, reflecting

. resolution of many of the audit findings as well as conflicting statements

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not consonant with the reported Part 10 CFR 21 issue On October 25, 1985, the NRC inspectors accompanied by the NED nuclear site engineering manager, made a partial plant walkdown in order to l observe physical hanger as-built conditions that were issues of the method l

used in stress calculations expressed by the consultant as lacking "suffi-cient conservatism" to compensate for problem areas. The NRC inspector also, visually examined the fillet weld on hanger 98-H-46919 which was a

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point of disagreement as to whether the weld area was properly cleaned I

. prior to welding. The inspectors observed that, although the weld

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appeared to. be sound, the weld has no structural significance. At the

. conclusion of the walkdown, the NRC inspector had no further questions

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,s: + regarding the finalfdisposition of the 10 CFR 21 report issue V

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In reviewing prior NRC' inspection reports, there were no direct references -

found that would indicate that the NRC resident inspectors had been

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4 cognizant of the specific audit involving the consultant; however, there 4 . were-adequate records to reflect continued inspection involvement and

' final concurrence by the NRC-resident inspectors regarding the redocumentation program by the licensee in response to IE Bulletin 79-1 No violations or deviations were identifie , Exit Interview-

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- An exit interview was conducted December 2, 1985, attended by.those indicated in paragraph 1. At this-time the SRI reviewed the scope and~

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findings of the inspectio ,

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